Report to the Ranking Minority

Member, Subcommittee on Interior and

Related Agencies, Committee on

Appropriations, House of

Representatives

United States General Accounting Office

GAO

November 2001 LAND MANAGEMENT

AGENCIES

Restoring Fish

Passage Through

Culverts on Forest

Service and BLM

Lands in Oregon and

Washington Could

Take Decades

GAO-02-136
Page i GAO-02-136 Culvert Fish Passage

Letter 1

Results in Brief 1

Background 3

Extent to Which Barrier Culverts Block Fish Passage Is Unknown 5

Several Factors Affect Agencies' Ability to Eliminate Barrier

Culverts Quickly 9

Ultimate Effectiveness of Agency Efforts to Restore Fish Passage

Is Largely Unknown Because Completed Projects Are Not

Systematically Monitored 15

Conclusions 20

Recommendation for Executive Action 20

Agency Comments 20

Appendix I Barrier Culvert Information by Bureau of Land

Management District Office and National Forest 22

Bureau of Land Management 22

Forest Service 23

Appendix II Comments From the Department of the Interior 25

Appendix III Comments From the Forest Service 26

Appendix IV Scope and Methodology 27

Appendix V GAO Contact and Staff Acknowledgments 29

GAO Contact 29

Acknowledgments 29

Tables

Table 1: BLM Fish Passage Barrier Culverts as of August 2001 23

Table 2: Forest Service Fish Passage Barrier Culverts as of

August 2001 24

Contents
Page ii GAO-02-136 Culvert Fish Passage

Figures

Figure 1: Culvert Before and After Replacement 5

Figure 2: Total Culverts Assessed and Barriers Estimated on BLM

and Forest Service Lands as of August 1, 2001 7

Figure 3: Sources of Funding for BLM Culvert Projects, Fiscal

Years 1998 Through August 1, 2001 11

Figure 4: Source of Funding for Forest Service Culvert Projects,

Fiscal Years 1998 Through August 1, 2001 12

Figure 5: Completed BLM and Forest Service Culvert Projects by

Fiscal Year 16
Page 1 GAO-02-136 Culvert Fish Passage

November 23, 2001

The Honorable Norm Dicks

Ranking Minority Member

Subcommittee on Interior

 and Related Agencies

Committee on Appropriations

House of Representatives

Dear Mr. Dicks:

The Bureau of Land Management, within the Department of the Interior,

and the Forest Service, within the U.S. Department of Agriculture, manage

over 41 million acres of federal lands in Oregon and Washington, including

122,000 miles of roads that use culverts–-pipes or arches made of concrete

or metal—to allow water to flow from one side of the road to the other.

Many of the streams that pass through these culverts are essential habitat

for fish and other aquatic species. When culvert openings are too high

above the streams for fish to jump into or culverts are positioned at a

grade too steep for fish to ascend, they pose barriers to fish attempting to

access their natural rearing and spawning habitat. Passage through

culverts is particularly important to anadromous fish, such as Coho and

Chinook salmon (some of which are threatened or endangered), which are

spawned in freshwater streams, but must travel to the ocean to mature,

then travel back to the streams to spawn. The two agencies are concerned

about the condition of the culverts on fish bearing streams on their Oregon

and Washington lands because many, either because of deterioration or

design, do not provide passage for all life stages (juvenile to adult) as

required by current standards.

In this context, you asked us to determine (1) the number of culverts that

may impede fish passage on Bureau of Land Management and Forest

Service lands in Oregon and Washington, (2) the factors affecting the

agencies' ability to restore passage through culverts acting as barriers to

fish (hereafter referred to as barrier culverts), and (3) the results of the

agencies' efforts to restore fish passage.

Over 10,000 culverts exist on fish-bearing streams in Oregon and

Washington according to Bureau of Land Management and the Forest

Service estimates, but neither agency knows the total number that impede

fish passage. Ongoing agency inventory and assessment efforts have

United States General Accounting Office

Washington, DC 20548

Results in Brief
Page 2 GAO-02-136 Culvert Fish Passage

already identified nearly 2,600 barrier culverts, but agency officials

estimate that more than twice that number may exist. The Forest Service

plans to complete its assessment by the end of calendar year 2001. The

Bureau of Land Management has not set a specific completion date for

assessing all culverts, but intends to continue assessing culverts as part of

its ongoing land management planning efforts. According to officials, both

agencies intend to use the assessments to assist them in planning and

setting priorities for eliminating barrier culverts. Based on current

assessments, the agencies estimate that efforts to restore fish passage may

ultimately cost over $375 million and take decades.

Although the agencies recognize the importance of restoring fish passage,

several factors are inhibiting agencies' efforts. Most significantly, the

agencies have not made sufficient funds available to do all the culvert

project work necessary. In allocating road maintenance funds, the

agencies assign a relatively low priority to such fish passage projects

because road safety is a higher priority than resource protection. As a

result, the agencies allocate most maintenance funding to address their

large road maintenance backlogs rather than to undertake culvert

projects. In addition, the often lengthy process of obtaining federal and

state environmental clearances and permits to perform culvert work, as

well as the short seasonal "window of opportunity" to do the work, affects

the agencies' ability to restore fish passages quickly. Furthermore, the

shortage of experienced engineering staff limits the number of projects

that the agencies can design and complete. Currently, each barrier

removal project generally takes 1 to 2 years from start to finish.

The Forest Service and the Bureau of Land Management completed 141

culvert projects from fiscal year 1998 through August 1, 2001, to remove

barriers to anadromous fish and to open an estimated 171 miles of fish

habitat. Neither agency, however, knows the extent to which culvert

projects ultimately result in improved fish passage because neither agency

requires systematic post-project monitoring to measure the outcomes of

their efforts. The agencies say they do not perform post-project monitoring

because of limited funding and staff availability and, according to agency

officials, because they assume culverts built using current standards on

lands under their jurisdiction should allow fish passage. State and local

entities using these same standards, however, require systematic postproject monitoring to ensure that they used the most effective methods for

improving fish passage under various conditions. Oregon's monitoring

results, for example, indicate that retrofitting culverts with devices that

slow the flow of water can effectively restore fish passage. Without

monitoring, neither the Forest Service nor the Bureau of Land
Page 3 GAO-02-136 Culvert Fish Passage

Management can ensure that the federal moneys expended to improve fish

passage are actually achieving the intended purpose. This report

recommends that both agencies develop guidance for systematically

assessing completed barrier removal projects to determine whether they

are improving fish passage as intended. The agencies agreed with our

recommendation for systematic monitoring.

The Bureau of Land Management (BLM) and the Forest Service manage

most of the nation's 655 million acres of federal land. BLM is responsible

for about 264 million acres of public lands, managed by 12 state offices

that are responsible for supervising the operations of 175 field offices

nationwide. The Forest Service is responsible for about 192 million acres

of public lands, managed by 9 regional offices that are responsible for

supervising the operations of 155 national forests.

BLM and the Forest Service manage about 93 percent of the 44 million

acres of federally owned land in Oregon and Washington. BLM's Oregon

State Office manages about 17 million acres of land in the two states,

including over 28,000 miles of roads. The state office directs the

operations of 10 district offices—9 in Oregon and 1 in Washington—-each

responsible for managing BLM's public land resources within its

geographic jurisdiction. Six of the Oregon districts contain Oregon and

California Grant Lands, distributed in a checkerboard pattern within each

district, and interspersed within and around the federal lands is state and

private lands. The Forest Service's Region 6 manages about 25 million

acres of land in the two states, including nearly 94,000 miles of roads.

Region 6 directs the operations of 19 national forests—13 in Oregon and 6

in Washington. BLM's district offices and the Forest Service's national

forest offices perform similar land management functions, including

restoration of fish and wildlife habitat and designing, constructing, and

maintaining roads.1

BLM and Forest Service land management activities regarding fish habitat

in Oregon and Washington are governed by three regional agreements: the

Northwest Forest Plan, signed in 1994 for activities on the west side of the

Cascade mountain range, and PACFISH and INFISH, signed in 1995, for

 1

 Unless otherwise stated, this report focuses on the activities of BLM's Oregon State Office

and districts and the Forest Service's Pacific Northwest Region 6 and corresponding

forests.

Background
Page 4 GAO-02-136 Culvert Fish Passage

activities on the east side of the range.2 Both agencies are required to

direct their land management activities toward achieving the objectives of

the three agreements. The Northwest Forest Plan's Aquatic Conservation

Strategy includes the objective of maintaining and restoring "connectivity

within and between watersheds," which must provide "unobstructed

routes to areas critical for fulfilling the life history requirements" of

aquatic species.3

 In addition, the Northwest Forest Plan's road

management guidelines state that the agencies shall "provide and maintain

fish passage at all road crossings of existing and potential fish-bearing

streams."4

 PACFISH includes the objective of achieving "a high level of

habitat diversity and complexity...to meet the life-history requirements of

the anadromous fish community inhabiting a watershed." The PACFISH

road management guidelines duplicate the Northwest Forest Plan

guidance. INFISH provides similar management objectives and guidance

for resident native fish outside of anadromous fish habitat.

Maintaining fish passage and habitat is particularly important for

anadromous fish, which as juveniles migrate up and down stream channels

seasonally, then travel from their freshwater spawning grounds to the

ocean where they mature, and finally return to their spawning grounds to

complete their life cycle. Under the authority of the Endangered Species

Act, the National Marine Fisheries Service currently lists four species of

salmon—including Coho, Chinook, Chum, and Sockeye—as well as

steelhead and sea-run trout as either threatened or endangered

anadromous fish in the northwest region. According to agency officials,

BLM and Forest Service lands in Oregon and Washington include

watersheds that represent some of the best remaining habitat for salmon

and other aquatic life, often serving as refuge areas for the recovery of

listed species. As such, unobstructed passage into and within these

watersheds is critical.

 2

 PACFISH is the common title for the Decision Notice/Decision Record, Environmental

Assessment, and Finding of No Significant Impact for interim management of anadromous

fish producing watersheds on federal lands in eastern Oregon and Washington, Idaho, and

portions of California. The Inland Native Fish Strategy (INFISH) is PACFISH's counterpart

for resident native fish outside of anadromous fish habitat.

3

 A watershed is an area of land that acts as a drainage basin contributing water, organic

matter, nutrients, and sediments to a stream or lake.

4

 Fish-bearing streams support fish during all or a portion of a typical year.
Page 5 GAO-02-136 Culvert Fish Passage

Culverts—-generally pipes or arches made of concrete or metal—-are

commonly used by BLM and the Forest Service to permit water to flow

beneath roads where they cross streams, thereby preventing road erosion

and allowing the water to follow its natural course. Culverts come in a

variety of shapes and sizes, designed to fit the circumstances at each

stream crossing, such as the width of the stream or the slope of the terrain.

Historically, agency engineers designed culverts for water drainage and

passage of adult fish. However, as a culvert ages, the pipe itself and

conditions at the inlet and outlet can degrade such that even strong

swimming adult fish cannot pass through the culvert. The agencies

remove, repair, or replace culverts to restore fish passage, as shown in

figure 1.

Figure 1: Culvert Before and After Replacement

Source: BLM's Eugene District Office.

To meet the objectives of the Northwest Forest Plan and PACFISH, as well

as Oregon and Washington state standards, current culvert repair or

replacement efforts must result in a culvert that allows the passage of all

life stages of fish, from juvenile to adult.

As of August 1, 2001, the agencies' fish passage assessments identified

almost 2,600 barrier culverts—over 400 on BLM lands and nearly 2,200 on

Forest Service lands—-and agency officials estimate that, in total, up to

5,500 fish barrier culverts may exist. BLM's 10 district offices are

collecting culvert information as part of their ongoing watershed analysis

activities and have not established a date for completing all culvert

assessments. The Forest Service, using a regionwide fish passage

assessment protocol, plans to complete data collection for all of its 19

Extent to Which

Barrier Culverts

Block Fish Passage Is

Unknown
Page 6 GAO-02-136 Culvert Fish Passage

forests by the end of calendar year 2001. The culvert information the

agencies are collecting will help them coordinate and prioritize culvert

repair, replacement, and removal efforts. Based on their current

knowledge of culvert conditions, the agencies project that to restore fish

passage at all barrier culverts could cost over $375 million and take

decades to finish.

BLM's district offices are assessing fish passage through culverts as part of

the ongoing land management activity of a watershed analysis. A

watershed analysis—-a systematic procedure to characterize the aquatic

(in-stream), riparian (near stream) and terrestrial (remaining land area)

features within a watershed—- is a requirement of the Northwest Forest

Plan and provides the foundation for implementing stream and river

enhancement projects, timber sales, and road building and

decommissioning projects. According to an agency official, the extent to

which a watershed analysis has been completed varies by district. The five

western Oregon districts entirely within the Northwest Forest Plan's

jurisdiction, which contain 98 percent of BLM's culverts on fish-bearing

streams, have completed watershed analyses for 87 to 100 percent of their

lands. The range for the remaining five districts is 0 to 18 percent. Each

BLM district office maintains its own records regarding barrier culverts on

its lands. As of August 1, 2001, BLM's district offices had assessed 1,152

culverts for fish passage and identified 414 barrier culverts. BLM plans to

continue its ongoing watershed analysis process, and estimates, based on

assessments to date, that an additional 282 barrier culverts may be

identified, for a total of 696 culverts blocking fish passage.

The Forest Service initiated a regionwide assessment of culverts on

fish-bearing streams in fiscal year 1999 to determine the scope of fish

passage problems and to create a database of culvert information that will

allow it to prioritize projects to address barrier culverts on a regionwide

basis. The region first developed written guidance and provided

implementation training to staff at each forest office. In fiscal year 2000, 13

of the 19 forests conducted the assessments and reported the results to the

region's fish passage assessment database. In fiscal year 2001, the

remaining six forest offices initiated their assessments and follow-up and

verification of the first year's results is ongoing. As of August 2001, the

forest offices had assessed 2,986 culverts for fish passage and identified

2,160—or about 72 percent—as barrier culverts. The region plans to

complete its assessment by December 2001, and based on its findings thus

far, estimates that an additional 2,645 barrier culverts may be identified,

for a total of 4,805 culverts blocking fish passage.

Agencies' Assessments to

Determine Maintenance

Status of Culverts Are

Ongoing
Page 7 GAO-02-136 Culvert Fish Passage

On the basis of information collected as of August 1, 2001, the two

agencies estimate a total of 10,215 culverts on fish-bearing streams under

their jurisdictions—2,822 culverts on BLM lands and 7,393 culverts on

Forest Service lands—as shown in figure 2.

Figure 2: Total Culverts Assessed and Barriers Estimated on BLM and Forest

Service Lands as of August 1, 2001

Source: BLM's Oregon State Office and the Forest Service's Region 6.

Detailed information on district and forest office culvert assessment

efforts is provided in appendix I.

Additional ground work is necessary before both agencies have complete

information on the extent of barrier culverts on their Oregon and

Washington lands, and as such, neither agency has established a process

for prioritizing passage restoration projects on a regionwide basis.

However, the agencies are using the fish passage information they have

Assessment Results Will

Help Prioritize Reduction

of Barrier Backlog
Page 8 GAO-02-136 Culvert Fish Passage

collected to help them coordinate and prioritize culvert repair,

replacement, and removal efforts on a more limited scale.

For example, officials at BLM's Coos Bay district stated that through the

ongoing culvert assessment process, they annually reprioritize culvert

projects for each resource area within the district and for each watershed

within each resource area, thus ensuring that the most critical barriers are

addressed first. In addition, according to BLM state office officials, some

culverts identified by district offices as fish passage barriers are included

in their deferred maintenance and capital improvement project backlog

and evaluated for funding among other road and facility projects. State

office officials stated that while culvert passage restoration projects have

not ranked high due to the critical nature of other backlog projects, they

expect barrier culvert projects to move up the list for funding as the

backlog is reduced.

National forest offices use their culvert fish passage assessment

information to assist them in prioritizing culvert maintenance activities

and for broader road management planning purposes. For example, in

fiscal year 2001, regional officials directed each forest office to identify its

top five culvert passage restoration projects when submitting its final

assessment report. The region considered these projects for funding;

however, according to a regional office official, it is not known how many

of these projects were actually completed. In addition, Olympic National

Forest officials stated that they have developed a draft road management

strategy that uses the fish passage assessment results as input to assist

them in further prioritizing of road projects identified by the strategy.

Although BLM and the Forest Service are currently addressing barrier

culverts based on the assessment information they have collected, agency

officials estimate, based on their results to date, that it may cost over

$375 million and take decades to restore fish passage at all barrier

culverts. BLM officials estimate a total cost of approximately $46 million

to eliminate their backlog of about 700 barrier culverts, while Forest

Service officials estimate a total cost of about $331 million to eliminate

their backlog of approximately 4,800 barrier culverts. At the current rate of

replacement, BLM officials estimate that it will take 25 years to restore

fish passage through all barrier culverts, and Forest Service officials

estimate that they will need more than 100 years to eliminate all barrier

culverts. Furthermore, these estimates do not reflect any growth in the

backlog due to future deterioration of culverts that currently function

properly.
Page 9 GAO-02-136 Culvert Fish Passage

According to BLM and Forest Service officials, several factors restrict

their ability to quickly address the long list of problem culverts. Of most

significance, the agencies assign a relatively low priority to such culvert

projects when allocating road maintenance funds because ensuring road

safety is the top priority for road maintenance, repair, and construction

funds. Both agencies emphasize reducing the backlog of road maintenance

rather than specifically correcting barrier culverts. Because neither agency

requests funds specifically for barrier culvert projects, district and forest

offices must fund these restoration projects within their existing budgets,

and these projects must compete with other road maintenance projects for

the limited funds. Therefore, to restore fish passage, the agencies largely

rely on other internal or external funding sources not dedicated to barrier

removal nor guaranteed to be available from year-to-year. Other factors

affecting the agencies' efforts to restore fish passage include the complex

and lengthy federal and state project approval process to obtain

environmental clearances and the limited number of agency engineers

experienced in designing culverts that meet current fish passage

requirements. Furthermore, to minimize disturbance to fish and wildlife

habitat, states impose a short seasonal "window of opportunity" within

which restoration work on barrier culverts can occur. As a result, each

barrier removal project generally takes 1 to 2 years from start to finish.

Both BLM and the Forest Service regard culverts as a component of their

road system—similar to bridges, railings, signs, and gates—each requiring

maintenance, including repair, replacement, and removal to ensure safe

operation. As such, each agency requests funding for road maintenance as

a total program of work rather than requesting funding specifically for

culvert maintenance, or more specifically, to restore fish passage at barrier

culverts. Furthermore, according to agency guidance, ensuring road safety

is the top priority for road maintenance activities rather than removing

barrier culverts.

Individual forest and district offices must fund culvert projects within their

road maintenance allocations, compete with other units for deferred

maintenance funds, or use other funding sources. BLM's state office and

the Forest Service's regional office each allocate annual road maintenance

funds to districts and forests primarily based on the miles of roads each

contains and distribute additional funds to those units for maintenance

projects on a competitive basis. BLM's fiscal year 2001 annual road

maintenance funding totaled about $6 million, while according to officials,

about $32 million is required to meet annual maintenance needs, including

culverts. The Forest Service's fiscal year 2001 annual road maintenance

Several Factors Affect

Agencies' Ability to

Eliminate Barrier

Culverts Quickly

Barrier Culvert Projects

Compete With Other Road

Maintenance Priorities for

Limited Funding
Page 10 GAO-02-136 Culvert Fish Passage

funding totaled about $32 million, while according to officials, about

$129 million is required to meet their annual maintenance needs, including

culverts. Due to their large backlogs of deferred maintenance, officials of

both agencies stated that deferred maintenance funds have not been

distributed to district or forest offices for fish passage restoration projects.

In the absence of sufficient road maintenance funding, the district and

forest offices largely rely on other internal or external funding sources not

specifically dedicated to barrier removal nor guaranteed to be available

from year-to-year to restore anadromous fish passage at barrier culverts.

As shown in figure 3, BLM's district offices reported that since fiscal year

1998, they relied almost entirely on Jobs-In-The-Woods program funding,

which seeks to support displaced timber industry workers within BLM's

Oregon and California Grant Lands. BLM distributes this funding to the

western districts in Oregon containing the Oregon and California Grant

Lands to fund contracts with local workers to do stream restoration

projects, including barrier culvert repair and replacement. While BLM

officials view the Jobs-In-The-Woods program as an ongoing source of

funding for culvert projects, this funding source is not dedicated to barrier

removal and BLM may use these funds for a variety of other resource

programs or projects. Other BLM barrier culvert project funding sources

include timber sales and the Federal Highway Administration's Emergency

Relief for Federally-owned Roads to replace storm-damaged culverts.
Page 11 GAO-02-136 Culvert Fish Passage

Figure 3: Sources of Funding for BLM Culvert Projects, Fiscal Years 1998 Through

August 1, 2001

Source: BLM's Oregon State Office.

As shown in figure 4, national forest offices reported that since fiscal year

1998 they have primarily relied on the Federal Highway Administration's

funding and the National Forest Roads and Trails funds for projects to

restore anadromous fish passage at barrier culverts. Due to severe

flooding in recent years and widespread damage to culverts, forest offices

obtained Federal Highway Administration funds to replace damaged

culverts and concurrently ensure these culverts meet current fish passage

standards. While such funds enabled the forest offices to address barrier

culverts, the forest offices cannot rely on future flood events to ensure a

steady stream of funding for such projects. National Forest Roads and

Trails funds consist of 10 percent of the receipts of the national forests

made available to supplement annual appropriations for road and trail

construction and projects that improve forest health conditions. Forest

offices used these funds to restore fish passage at barrier culverts and to

fund their ongoing culvert fish passage assessment effort. These funds,
Page 12 GAO-02-136 Culvert Fish Passage

however, are not dedicated to fish passage projects, but rather culvert

projects compete with other road projects for these funds on a regionwide

basis. Other funding sources for Forest Service fish passage projects

include Jobs-In-The-Woods and timber sales.5

Figure 4: Source of Funding for Forest Service Culvert Projects, Fiscal Years 1998

Through August 1, 2001

Source: The Forest Service's Region 6.

 5

 According to Forest Service officials, Jobs-In-The-Woods funds are no longer available.
Page 13 GAO-02-136 Culvert Fish Passage

In addition to limitations on the amount of funding available for barrier

culvert projects and uncertainty regarding the continuity of such funding,

three other factors affect the agencies' efforts to restore fish passage.

These factors are (1) the complex and lengthy federal and state project

approval process, (2) the limited number of agency engineers with

experience designing culverts that meet current fish passage standards,

and (3) the short seasonal "window of opportunity" during which work on

barrier culverts can occur. Each of these factors affects the time frame

needed to complete each of the major phases of a barrier culvert project—

specifically, obtaining necessary permits and clearances, designing the

culvert, and constructing the culvert—and consequently impacts the

number of projects that can be completed annually. Due to these factors,

culvert projects to restore culvert fish passage take 1 to 2 years to

complete, according to BLM and Forest Service officials.

First, BLM and Forest Service officials stated that the number of fish

passage projects the agencies can undertake and the speed with which

they can be completed depend largely on how long it takes to obtain the

various federal and state clearances necessary to implement a culvert

project. Under the National Environmental Policy Act, an assessment of

each project's impact on the environment must be completed before

construction can commence. If the assessment indicates that an

endangered species may be adversely affected by the project, Section 7 of

the Endangered Species Act of 1973 requires the agency to consult with

the appropriate authority—generally the National Marine Fisheries Service

for anadromous fish and the Fish and Wildlife Service for other species—

to reach agreement on how to mitigate the disturbance. BLM and the

Forest Service have entered into an agreement with the consulting

agencies to expedite the process through streamlined procedures.

However, according to agency representatives, factors such as staffing

shortages and turnover, as well as differing interpretations of the

streamlining guidance, have prevented the revised consultation process

from producing the efficiencies desired by the agencies, and it is currently

under review. In addition to consultation:

• the U.S. Army Corps of Engineers requires a permit for fill or excavation in

waterways and wetlands;

• Oregon requires a "removal and fill" permit for in-stream construction; and

• Washington requires a hydraulic project permit to engage in construction

activities within streams.

According to information provided by district and forest offices for 56

completed culvert projects, the clearance and permit process is the most

Factors Affecting Project

Design, Approval, and

Construction Restrict

Agencies' Efforts to

Eliminate Barriers
Page 14 GAO-02-136 Culvert Fish Passage

time-consuming phase of a culvert project, ranging from a low of 4 weeks

to a high of 113 weeks, for an average of about 31 weeks.

Second, BLM's and the Forest Service's efforts to eliminate barrier

culverts are restricted, according to agency officials, by the limited

number of engineers available to design them, and more specifically, the

few with experience in designing culverts that meet current fish passage

requirements. As a result, district and forest officials speculate that

additional hiring or contracting with engineering firms for culvert design

work may be necessary if greater emphasis is placed on reducing the

barrier culvert backlog. Agency officials also emphasized the need for

more fish biologists, hydrologists, and other professionals with fish

passage design skills. According to time frame information provided by

district and forest offices for 56 completed culvert projects, the design

process is the second most time-consuming phase of a project, ranging

from a low of 4 weeks to a high of 78 weeks to complete, for an average of

about 19 weeks.

Finally, BLM and Forest Service officials stated that their efforts to

eliminate barrier culverts are limited by a short seasonal "window of

opportunity" of about 3 months during which fish passage restoration

work—that is, construction work within streams— can occur. Oregon and

Washington have established these time frames to minimize the impacts to

important fish, wildlife, and habitat resources. The summer to fall instream work time frames, when construction is most feasible due to low

water flow, most commonly run from July to September, but could be as

narrow as July 15 to August 15, or just 1 month. According to time frame

information provided by district and forest offices for 56 completed

culvert projects, construction is the least time-consuming phase of a

project, ranging from a low of 4 weeks to a high of 61 weeks to complete,

for an average of about 10 weeks.

According to BLM and Forest Service officials, the minimum time

necessary to complete a barrier culvert project, if all phases of the project

are completed in the shortest possible time frame, is about 1 year.

However, due to the factors discussed above, projects are more likely to

take over a year to complete. The consequences of a delay caused by any

one of the factors have a cascading effect on the project completion date.

For example, according to agency officials, they generally begin a project

by initiating the clearance and permit process and collecting some

preliminary engineering information. However, if project clearances are

not obtained or imminent by March when project funding decisions are

made, construction may be put off to the next year, rather than committing
Page 15 GAO-02-136 Culvert Fish Passage

funds to a project that may not be ready for implementation within the

seasonal time frames. Similarly, project clearances may be completed

timely, but the project may be delayed if an engineer with fish passage

design experience is not available. And, if all phases of a project, including

construction contracts, are not in place in time to complete construction

within the state-mandated stream construction time frames, the project

must be put off until the next season. According to the information

provided by district and forest offices for 56 projects, the total time to

complete a project ranged from a low of 16 weeks to a high of 186 weeks,

for an average of 60 weeks.

BLM and the Forest Service completed 141 projects to restore fish passage

for anadromous fish at barrier culverts from fiscal year 1998 through July

2001 and opened access to an estimated 171 miles of fish habitat.

However, because neither agency requires systematic monitoring of these

completed projects, the actual extent of improved fish passage is largely

unverified. According to agency officials, current culvert fish passage

design standards are based on scientific research that considers such

factors as the swimming ability of fish at various life stages and the

velocity of water. Therefore, the officials assume that fish can migrate into

the newly accessible habitat through culverts built to these standards.

Furthermore, agency officials cite a lack of funds and available staff as

reasons for not requiring systematic post-project monitoring.

While district and forest offices may monitor projects on a limited or ad

hoc basis, whether both juvenile and adult fish can actually pass through

the restored culvert or actually inhabit the upstream areas is not

systematically determined. However, the Oregon and Washington state

fish passage restoration programs, as well as other local efforts, require

systematic post-project monitoring to determine the most effective

methods for improving fish passage under various conditions. Without

such monitoring, neither the Forest Service nor BLM can ensure that the

federal moneys expended for improving fish passage are actually

achieving the intended purpose.

As shown in figure 5, BLM reported 68 projects completed to restore fish

passage for anadromous fish at barrier culverts from fiscal year 1998

through August 1, 2001, opening access to an estimated 95 miles of fish

habitat. During the same time frame, the Forest Service reported 73

projects completed to restore fish passage for anadromous fish at barrier

culverts and opened access to an estimated 76 miles of fish habitat.

Ultimate

Effectiveness of

Agency Efforts to

Restore Fish Passage

Is Largely Unknown

Because Completed

Projects Are Not

Systematically

Monitored

Forest Service and BLM

Do Not Require

Post-Project Monitoring
Page 16 GAO-02-136 Culvert Fish Passage

Figure 5: Completed BLM and Forest Service Culvert Projects by Fiscal Year

Note: Fiscal year 2001 includes only projects completed as of August 1, 2001.

Source: BLM's Oregon State Office and the Forest Service's Region 6.

The actual extent of improved fish passage is largely unknown, however,

because neither agency requires systematic post-project monitoring of

completed projects. Forest and district offices undertake a wide range of

activities in and around streams to restore aquatic habitat. These activities

include eliminating fish passage barrier culverts, as well as other activities

such as stabilizing eroding stream banks, planting vegetation, and placing

desirable woody debris and boulders into the streams. While each forest

and district office is required to conduct monitoring of selected

restoration activities, neither agency specifically requires barrier culvert

projects be monitored. Therefore, restoration projects selected by district

and forest offices for monitoring may or may not include barrier culvert

passage projects. Consequently, the agencies do not systematically

determine whether fish can actually pass through repaired or replaced
Page 17 GAO-02-136 Culvert Fish Passage

culverts. Furthermore, while the miles of habitat theoretically made

accessible to fish is estimated, the extent to which fish actually inhabit

that stream area is not routinely determined.

BLM and Forest Service officials stated that monitoring all culvert fish

passage projects would be a costly and time-consuming effort for their

already limited staff. Therefore, district and forest staff stated that culvert

project follow-up is generally ad hoc in nature. For example, subsequent to

project completion, the designing engineer will likely look to see if water

appears to be flowing through the culvert as designed, or the fish biologist

that helped plan a project may walk up the stream side looking for egg

beds to ascertain the presence of fish. However, according to agency

officials, a formalized, comprehensive measurement of results, for

example, requiring engineers to measure water flows through all

completed culverts or biologists to count egg beds in every area of a newly

opened habitat is not feasible at current funding and staffing levels. One

forest official stated that ideally, every project should have monitoring

funds included with the project funds to verify effectiveness, but funding

realities have not made this possible.

According to BLM and Forest Service officials, in the absence of

systematic monitoring, they assume that culverts built to current

standards will allow fish migration into the newly accessible habitat.

Current culvert design standards are based on scientific research that

considers important factors such as the swimming capabilities of fish at

various life stages and the velocity of water to guide engineers in building

culverts that will allow passage of juvenile to adult fish. BLM primarily

follows the standards published by the Oregon State Department of Fish

and Wildlife, and the Forest Service follows those same Oregon standards

or the Washington Department of Fish and Wildlife's standards, depending

on the project's location. Where appropriate, the current standards

endorse the use of open bottom culverts that simulate natural stream

bottoms and slopes and culvert widths that adhere to the stream's natural

width, mimicking the stream's natural features to the greatest extent

possible.

However, even culvert projects built to current standards may not

necessarily result in improved fish passage. District and forest officials

characterized culvert fish passage design as an evolving area of study. For

example, according to federal and state officials, retrofitting culverts by

adding staggered or perforated panels inside to slow down water

velocities is a complex design process only applicable in limited

circumstances. Another area of concern, according to Forest Service
Page 18 GAO-02-136 Culvert Fish Passage

officials, is the length of culverts because questions remain as to how far

fish will swim inside a dark culvert. Furthermore, during our field visits to

completed culvert project sites, we observed culverts that, according to

agency officials, continued to be barriers to fish passage, including a

retrofitted culvert that did not sufficiently slow water flow, a replaced pipe

that did not allow juvenile fish passage, and a culvert that allowed water to

flow under it rather than through it.

Systematic post-project monitoring is a requirement of the Oregon and

Washington state fish passage restoration efforts on state lands, as well as

cooperative local programs on other lands within the states and has

helped these programs to identify ways to enhance the effectiveness of

fish passage projects. According to an Oregon Department of Fish and

Wildlife official, in fiscal year 1999 the state implemented a protocol for

systematically monitoring and documenting the results of culvert retrofit

projects to improve fish passage. The protocol, jointly developed by

Oregon's Department of Fish and Wildlife and Department of

Transportation, requires monitoring the movement of water in and around

retrofitted culverts to determine if fish passage is improved. In the first

year of implementation, the agencies systematically monitored selected

culverts retrofitted in 1998 within certain state regions, including visual

inspections and water velocity measurements taken at different times to

assess how well the retrofit designs slowed water velocity. The monitoring

results indicated the retrofit designs, while needing some adjustments,

improved fish passage by slowing water and reducing culvert entry jump

heights for fish. According to the state official, the agencies are currently

developing fish passage monitoring protocols for culverts that have been

replaced rather than retrofitted.

The Washington Department of Fish and Wildlife, in partnership with the

state Department of Transportation, developed and implemented a threelevel culvert and fish use evaluation procedure for all culvert retrofit or

replacement projects funded by the state's Fish Passage Barrier Removal

Program. Agreeing that the best management practice is to avoid "walking

away" from a fish passage project once construction is complete, the

agencies are systematically assessing culvert projects for design, durability

and efficiency; determining if fish use the newly available habitat; and

troubleshooting problems identified. The three-level evaluation involves

the following steps:

• First, fish use before and after project completion is determined, and each

completed project is evaluated for durability, efficiency, and design flaws,

Post-Project Monitoring

Could Help Identify the

Most Effective Fish

Passage Restoration

Methods
Page 19 GAO-02-136 Culvert Fish Passage

which are corrected during the year following project completion. The

culvert is removed from the monitoring list if fish passage is verified and

no additional monitoring is required.

• Second, for culverts where fish passage is not occurring, additional

monitoring for fish presence is implemented, and if necessary, other

methods to support fish recovery, including supplementation such as

planting of hatchery fish, fishing restrictions, or stream habitat

improvement projects, are implemented.

• Third, selected culverts are studied to determine the overall impact on fish

populations.

Evaluation results as of April 2001 indicated most habitats reclaimed

through culvert projects were immediately populated by fish; however,

varied responses on some streams require additional monitoring and

possibly further enhancement efforts to promote fish recovery.

In addition to the state monitoring efforts, local fish passage restoration

plans may also require systematic monitoring of project results to ensure

they are successful. For example, Oregon's Rogue River Basin Fish Access

Team, composed of local stakeholders, watershed councils, and state and

federal agencies (including BLM and the Forest Service), has established a

basinwide strategic plan to cooperatively prioritize fish passage barriers,

secure funding for projects, implement passage enhancement projects, and

monitor the success of projects. Specifically, to participate in the program,

a monitoring plan must be completed for each project before the project

begins. The monitoring plan must determine whether the project was

implemented as planned, was effective in solving fish passage problems,

and contributed to the expanding fish distribution across the Rogue River

basin. Potential techniques suggested to determine effectiveness include

spawning and snorkeling (underwater observation) surveys.

As their actions demonstrate, Oregon, Washington, and other entities

consider systematic monitoring to be an important tool to determine the

most effective methods for improving fish passage under various

conditions. The systematic monitoring allows the entities to incorporate

this knowledge into future restoration planning and implementation. Their

varied approaches reflect the range of methods available for monitoring—

that is, monitoring improvements to water flow at selected culverts of a

specific design type, verifying the actual presence of fish in a newly

opened habitat, or developing monitoring plans for specific projects. While

each monitoring approach requires a commitment of agency staff and

funding to implement, they all provide valuable information for targeting

future expenditures on culvert passage restoration methods that most
Page 20 GAO-02-136 Culvert Fish Passage

benefit fish. Oregon and Washington's monitoring efforts have helped

them to assess the success of various culvert passage restoration methods

and identified methods that require adjustments or further study to

determine their effectiveness. Without such systematic monitoring

programs, neither the Forest Service nor BLM can ensure that the federal

moneys expended for improving fish passage are actually achieving the

intended purpose.

BLM and the Forest Service are faced with the daunting task of addressing

a large backlog of fish passage barrier culverts. Given the limited funding

available for fish passage projects and the various factors that affect the

agencies' ability to complete projects quickly, eliminating barrier culverts

will be a long, costly effort. While both agencies are already using culvert

assessment information to help them prioritize projects, that is just the

beginning of the barrier elimination process. Ultimately, the culvert

projects selected for implementation—whether retrofitting existing

culverts, replacing culverts, or removing culverts—must achieve the

objective of restoring fish passage. Systematic monitoring of completed

projects would provide the agencies with information to help them

identify which methods actually work best under various circumstances

and evidence that their expenditures have actually improved fish passage.

Although monitoring would divert funding and staff from the

implementation of culvert passage improvement projects, state monitoring

programs have demonstrated the value of monitoring to assess the

effectiveness of barrier culvert projects and to allow these entities to

incorporate this knowledge into future planning and implementation

efforts.

To determine whether fish passage restoration projects are achieving their

intended purpose, we recommend that the Director of BLM and the Chief

of the Forest Service each develop guidance for systematically monitoring

completed barrier removal projects. This guidance should establish

procedures that will allow the agencies to cost-effectively measure and

document improvements to fish passage.

We provided the Department of the Interior and the Forest Service with a

draft of this report for comment prior to issuance. The agencies generally

agreed with the content of the report and concurred with our

recommendation for systematic monitoring so long as agency officials

have the discretion to determine the monitoring approaches and

Conclusions

Recommendation for

Executive Action

Agency Comments
Page 21 GAO-02-136 Culvert Fish Passage

methodologies that will most benefit them in planning and implementing

future fish passage projects. We recognize that the agencies will have to

exercise discretion in developing this guidance, but they need to ensure

that they implement a monitoring program that cost-effectively measures

and documents improvements to fish passage. The agencies also provided

certain technical clarifications, which we incorporated, as appropriate, in

the report. Copies of the agencies' comments are included as appendixes

II and III.

We conducted our review from March 2001 through October 2001 in

accordance with generally accepted government auditing standards.

Details of our scope and methodology are discussed in appendix IV.

We are sending copies of this report to the Director of the Bureau of Land

Management and the Chief of the Forest Service. We will also provide

copies to others on request.

If you or your staff have any question about this report, please call me at

(202) 512-3841. Key contributors to this report are listed in appendix V.

Sincerely yours,

Barry T. Hill

Director, Natural Resources

 and Environment
Appendix I: Barrier Culvert Information by

Bureau of Land Management District Office

and National Forest

Page 22 GAO-02-136 Culvert Fish Passage

The Bureau of Land Management (BLM) and the Forest Service are

assessing culverts on their lands in Oregon and Washington to identify

barriers to fish passage. Neither agency has completed this effort, but each

of the 10 district and 19 forest offices provided their assessment results as

of August 1, 2001. In addition, each district and forest office provided the

estimated total number of culverts on fish-bearing streams, an estimated

number of culverts not yet assessed that may be barriers, and an estimated

cost to restore fish passage through barrier culverts.

BLM districts reported that they have assessed 1,152 culverts for fish

passage and identified 414 barriers. In addition, the districts estimate that

282 additional barrier culverts may exist. BLM estimates that the cost to

restore fish passage at all 696 of these barrier culverts could be about

$46 million, as shown in table 1.

Appendix I: Barrier Culvert Information by

Bureau of Land Management District Office

and National Forest

Bureau of Land

Management
Appendix I: Barrier Culvert Information by

Bureau of Land Management District Office

and National Forest

Page 23 GAO-02-136 Culvert Fish Passage

Table 1: BLM Fish Passage Barrier Culverts as of August 2001

Dollars in thousands

BLM district

Estimated

number of

culverts on

fish-bearing

streams

Number of

culverts

assessed for

fish passage

Number of

barrier culverts

identified

Number of

barrier culverts

estimated

Total number of

barrier culverts

identified and

estimated

Estimated cost

to restore fish

passage at

barrier culverts

Oregon

Burns 2 2 0 0 0 0

Coos Bay 960 92 33 55 88 $2,561

Eugene 284 264 112 20 132 8,404

Lakeview 53 16 1 3 4 313

Medforda167 154 57 10 67 7,931

Prineville 2 2 0 0 0 0

Roseburga879 500 150 30 180 19,800

Salem 466 117 60 164 224 7,425

Valea4 0 UnknownbUnknownbUnknownbUnknownb

Oregon total 2,817 1,147 413 282 695 $46,434

Washington

Spokane 5 5 1 0 1 13

Total all

districts

2,822 1,152 414 282 696 $46,447

a

Data reported by Medford, Roseburg, and Vale Districts do not include culverts on streams bearing

resident fish only.

b

Vale district did not provide estimates as of August 1, 2001.

Source: BLM.

Forest Service national forest offices reported that they have assessed

2,986 culverts for fish passage and identified 2,160 barriers. In addition,

they estimate that an almost equal number, about 2,645, of additional

barrier culverts may exist. The Forest Service estimates that the cost to

restore fish passage at all 4,805 barrier culverts could be about

$331 million, as shown in table 2.

Forest Service
Appendix I: Barrier Culvert Information by

Bureau of Land Management District Office

and National Forest

Page 24 GAO-02-136 Culvert Fish Passage

Table 2: Forest Service Fish Passage Barrier Culverts as of August 2001

Dollars in thousands

National forest

Estimated

number of

culverts on

fish-bearing

streams

Number of

culverts

assessed for

fish passage

Number of

barrier culverts

identified

Number of

barrier culverts

estimated

Total number of

barrier culverts

identified and

estimated

Estimated cost

to restore fish

passage at

barrier culverts

Oregon

Deschutes 200 180 134 0 134 $24,232

Fremont 600 177 138 262 400 10,000

Malheur 1,000 50 40 760 800 20,000

Mt. Hood 397 247 237 142 379 18,200

Ochoco 600 52 42 420 462 21,800

Rogue River 310 106 88 0 88 5,560

Siskiyou 198 198 132 0 132 13,000

Siuslaw 540 491 270 0 270 25,427

Umatilla 392 200 180 0 180 33,000

Umpqua 236 107 96 116 212 Unknowna

Wallowa-Whitman Unknowna0 0 UnknownaUnknownaUnknowna

Willamette 991 323 310 116 426 77,000

Winema 120 0 0 80 80 2,000

Oregon total 5,584 2,131 1,667 1,896 3,563 $250,219

Washington

Colville 250 100 0 50 50 Unknowna

Gifford Pinchot 500 100 0 425 425 38,000

Mt. BakerSnoqualmie250 130 56 67 123 10,701

Okanogan 150 77 74 66 140 8,000

Olympic 142 119 119 0 119 16,422

Wenatchee 517 329 244 141 385 7,700

Washington total 1,809 855 493 749 1,242 $80,823

Total all forests 7,393 2,986 2,160 2,645 4,805 $331,042

a

According to the Forest Service, the Umpqua, Wallow-Whitman, and Colville national forests did not

provide estimates because their fish passage assessments were not complete.

Source: The Forest Service.
Appendix II: Comments From the Department

of the Interior

Page 25 GAO-02-136 Culvert Fish Passage

Appendix II: Comments From the

Department of the Interior
Appendix III: Comments From the Forest

Service

Page 26 GAO-02-136 Culvert Fish Passage

Appendix III: Comments From the Forest

Service
Appendix IV: Scope and Methodology

Page 27 GAO-02-136 Culvert Fish Passage

To determine the number of culverts that may impede fish passage on

BLM and Forest Service lands in Oregon and Washington, we interviewed

officials and gathered documentation from BLM's Oregon State Office and

the Forest Service's Region 6 office, both located in Portland, Oregon.

Specifically, we gathered and analyzed information on the number and

maintenance status of culverts located in the 10 BLM districts under

Oregon State Office jurisdiction and the 19 national forests under Region 6

jurisdiction and the costs and time frames associated with the repair of

barrier culverts. We conducted site visits at four BLM district offices in

Oregon—Coos Bay, Eugene, Medford, and Prineville—and at nine national

forest offices—Deschutes, Ochoco, Rogue River, Siskiyou, Siuslaw,

Umatilla, and Williamette in Oregon; and Gifford Pinchot and Olympic in

Washington. We met with district and forest office staff and collected

information on their culvert inventories and assessment and prioritization

efforts and observed completed and potential culvert restoration projects.

To identify the factors affecting the agencies' ability to restore passage

through culverts acting as barriers to fish, we interviewed BLM and Forest

Service headquarters officials, Oregon State Office and Region 6 officials,

and district and forest office staff and reviewed policies, procedures, and

practices for repairing, replacing, or removing barrier culverts. We

gathered and analyzed funding information for 141 anadromous fish

passage culvert projects completed in Oregon and Washington from fiscal

year 1998 through July 2001, including the amount and source of funds

expended for each project. We analyzed detailed time line information for

56 of the 141 projects that included complete start and finish dates for the

three main phases of each project—federal and state clearances, design

and engineering, and construction. We interviewed agency officials and

gathered documentation to identify the factors that affect project time

frames and to determine how these factors limit the number of culvert

projects that can be completed annually.

To determine the results of the agencies' efforts to restore fish passage, we

gathered and analyzed information on the number of (1) culverts repaired,

replaced, or removed to improve anadromous fish passage and (2) miles of

habitat restored from fiscal year 1998 through August 1, 2001, by district

and forest offices under Oregon State Office and Region 6 jurisdiction. We

interviewed BLM and Forest Service headquarters, state and regional

office, and district and forest office officials and reviewed documentation

to determine whether regulations, policies, and procedures required

systematic monitoring of the effectiveness of the culvert restoration

projects. To identify state efforts to monitor the outcome of fish passage

projects, we interviewed Oregon and Washington state officials and

Appendix IV: Scope and Methodology
Appendix IV: Scope and Methodology

Page 28 GAO-02-136 Culvert Fish Passage

reviewed regulations, policies, and procedures and monitoring reports

provided by the state agencies with fish passage restoration

responsibilities.

We conducted our work from March 2001 through October 2001 in

accordance with generally accepted government auditing standards.
Appendix V: GAO Contact and Staff

Acknowledgments

Page 29 GAO-02-136 Culvert Fish Passage

Linda Harmon (202) 512-8046

In addition to the above, Leo Acosta, Kathy Colgrove-Stone, and

Brad Dobbins made key contributions to this report.

Appendix V: GAO Contact and Staff

Acknowledgments

GAO Contact

Acknowledgments

(360052)

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